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Articles

The Wiz in the Witch Hunt: Milton Stewart, the FCC, and the FBI

 

Abstract

Milton D. Stewart was an innovative and influential young media reformer of the mid- and late 1940s. He intersected with some of the most eminent figures in the field, including Robert M. Hutchins and the Commission on Freedom of the Press. At age twenty-two, Stewart made regulatory history by persuading the Federal Communications Commission to accept content analysis as evidence in a licensing proceeding. A few years later, a former landlady’s allegations led to an exhaustive FBI investigation of Stewart’s associations, writings, beliefs, and personal life, including his views on media reform. Although media-related writing and activism were not proximate causes of the Stewart probe, this study argues that his case illustrates the nature of information that the FBI could gather, including matters far afield from national security.

Notes

1 Milton Stewart, “FM: Radio Wave of the Future,” Common Sense, October 1945, 32.

2 “WHKC Battle Fails to Build Political Case,” Billboard, September 2, 1944, 7.

3 Victor Pickard, “Charles Siepmann’s Forgotten Legacy for Communication Research and Media Policy,” in The International History of Communication Study, edited by Peter Simonson and David W. Park, (New York: Routledge, 2015), 263.

4 Elizabeth Fones-Wolf, Waves of Opposition: Labor and the Struggle for Democratic Radio (Urbana: University of Illinois Press, 2006). Kathy M. Newman also devotes a chapter to a CIO boycott in Radio Active: Advertising and Consumer Activism, 1935-1947 (Berkeley: University of California Press, 2004), 81–108.

5 Victor Pickard, “Media Activism from Above and Below: Lessons from the 1940s American Reform Movement,” Journal of Information Policy 5 (2015): 110; Victor Pickard, “The Battle Over the FCC Blue Book: Determining the Role of Broadcast Media in a Democratic Society, 1945-1948,” Media, Culture and Society 33 (2011): 171–91; Victor Pickard, “The Strange Life and Death of the Fairness Doctrine: Tracing the Decline of Positive Freedoms in American Policy Discourses,” International Journal of Communication 12 (2018): 3434–53; Victor Pickard, “‘The Air Belongs to the People’: The Rise and Fall of a Postwar Radio Reform Movement,” Critical Studies in Media Communication 30 (2013): 307–26; Victor Pickard, “The Postwar Media Insurgency: Radio Activism from Above and Below,” in Media Interventions, edited by Kevin Howley (New York: Peter Lang, 2013), 249–66; Victor Pickard, “The Revolt Against Radio: Postwar Media Criticism and the Struggle for Broadcast Reform,” in A Moment of Danger: Critical Studies in the History of US Communication Since World War II, edited by Janice Peck and Inger L. Stole (Milwaukee: Marquette University Press, 2011), 35–56. See generally Victor Pickard, America’s Battle for Media Democracy: The Triumph of Corporate Libertarianism and the Future of Media Reform (New York: Cambridge University Press, 2015). An important work focusing on an earlier period, the late 1920s to the mid-1930s, is Robert W. McChesney, Telecommunications, Mass Media, and Democracy: The Battle for the Control of US Broadcasting, 1928-1935 (New York: Oxford University Press, 1993).

6 Steven J. Simmons, The Fairness Doctrine and the Media (Berkeley: University of California Press, 1978).

7 Fones-Wolf, Waves of Opposition, 119–24; Pickard, “‘Air Belongs to the People,’” 313–4; Simmons, Fairness Doctrine, 38–9; Llewellyn White, The American Radio: A Report on the Broadcasting Industry in the United States from the Commission on Freedom of the Press (Chicago: University of Chicago Press, 1947), 80–2; Charles A. Siepmann, Radio’s Second Chance (Boston: Little, Brown, 1946), 109–14; Herta Herzog, “Radio—The First Post-War Year,” Public Opinion Quarterly 10 (1946): 303.

8 Amy Lyn Toro, “Standing Up for Listeners’ Rights: A History of Public Participation at the Federal Communications Commission” (PhD dissertation, University of California, 2000), 112–3.

9 Commission on Freedom of the Press, A Free and Responsible Press: A General Report on Mass Communication (Chicago: University of Chicago Press, 1947).

10 White, American Radio.

11 Jerilyn S. McIntyre, “Repositioning a Landmark: The Hutchins Commission and Freedom of the Press,” Critical Studies in Mass Communication 4 (1987): 136–60; Stephen Bates, An Aristocracy of Critics: Luce, Hutchins, Niebuhr, and the Committee That Redefined Freedom of the Press (New Haven, CT: Yale University Press, 2020); Pickard, America’s Battle for Media Democracy, 124–89. All three scholars address the Hutchins Commission in other writings, too.

12 David Goodman, Radio’s Civic Ambition: American Broadcasting and Democracy in the 1930s (New York: Oxford University Press, 2011), 301–11. Outside the broadcast realm, Sam Lebovic uses Commission documents for a brief discussion of conceptions of freedom in Free Speech and Unfree News: The Paradox of Press Freedom in America (Cambridge: Harvard University Press, 2016), 138–45.

13 Tim Weiner, Enemies: A History of the FBI (New York: Random House, 2012), 131–87; Athan G. Theoharis, The FBI and American Democracy: A Brief Critical History (Lawrence: University of Kansas, 2004), 65–104; Athan G. Theoharis, “The Truman Presidency and the FBI,” in Civil Liberties and the Legacy of Harry S. Truman, edited by R. S. Kirkendall (Kirksville, MO: Truman State University Press, 2012), 37–66. See also Athan G. Theoharis, ed., The FBI: A Comprehensive Reference Guide (Phoenix: Oryx Press, 1999).

14 Landon R. Y. Storrs, The Second Red Scare and the Unmaking of the New Deal Left (Princeton: Princeton University Press, 2013); Landon R. Y. Storrs, “Revisiting Truman’s Federal Employee Loyalty Program,” in Civil Liberties and the Legacy of Harry S. Truman, 67–80; Louise S. Robbins, “The Library of Congress and Federal Loyalty Programs, 1947–1956: No ‘Communists or Cocksuckers,’” Library Quarterly 64, no. 4 (1994): 365–85; Susan L. Brinson, The Red Scare, Politics, and the Federal Communications Commission, 1941–1960 (Westport, CT: Praeger, 2004), 103–4.

15 John A. Lent, ed., A Different Road Taken: Profiles in Critical Communication (Boulder, CO: Westview, 1995), 28, 30–2, 34–6 (Smythe), 93 (Gerbner); George Seldes, Witness to a Century: Encounters with the Noted, the Notorious, and Three SOBs (New York: Ballantine Books, 1987); Matthew Cecil, Hoover’s FBI and the Fourth Estate: The Campaign to Control the Press and the Bureau’s Image (Lawrence: University Press of Kansas, 2014), 101–55; Loren Ghiglione, CBS’s Don Hollenbeck: An Honest Reporter in the Age of McCarthyism (New York: Columbia University Press, 2008); Pickard, America’s Battle, 73–4, 97; Pickard, “Battle Over the Blue Book,” 183–4, 186–7; Pickard, “Charles Siepmann’s Forgotten Legacy,” 271; Pickard, “‘Air Belongs to the People,’” 317; Pickard, “Reopening the Postwar Settlement,” 179, 183; Pickard, “Revolt Against Radio,” 53.

16 FBI files on Milton Stewart obtained by author via Freedom of Information Act request; Finding aid to the Milton D. Stewart Papers, Arizona State University Library, Tempe, http://www.azarchivesonline.org/xtf/view?docId=ead/asu/stewart_acc.xml;query=;brand=default; Senator Nelson (WI), “Small Business Administration,” Congressional Record (July 18, 1978), S21258; Milton D. Stewart, “Education of a Small Businessperson,” Inc., June 1983, https://www.inc.com/magazine/19830601/4850.html?cid=search. In 2012, the author submitted a Freedom of Information Act (FOIA) request to the FBI seeking records on Stewart. The bureau released 395 pages on CD after about a year. After consulting with other government agencies, the FBI released a handful of additional documents as late as 2019.

17 Stewart, “Education of a Small Businessperson.”

18 Ibid.; Herbert Brucker, Freedom of Information (New York: Macmillan, 1949), 293.

19 “The Stewart Tapes: Conversations Between Milton D. Stewart and Abigail J. Stewart,” unpublished transcript of interviews conducted in November 1995, p. 88 (copy in author’s possession); Stewart, “Education of a Small Businessperson.”

20 Stewart, “Education of a Small Businessperson.”

21 “Stewart Tapes,” 89–90; Milton D. Stewart, “Goebbaloney by Radio,” Louisville Courier-Journal, July 9, 1944, 10.

22 Correspondence from Robert D. Leigh to Charles E. Merriam, 24 August 1944, 1, box 65, Charles E. Merriam Papers, University of Chicago; “Stewart Tapes,” 89, 92–3.

23 Milton D. Stewart, “Importance in Content Analysis: A Validity Problem,” Journalism Quarterly 20, no. 4 (December 1943): 286–93; Bruce Lannes Smith with Milton D. Stewart, “Bibliography,” Public Opinion Quarterly 8, no. 2 (Summer 1944): 304–14.

24 “Small Business and the Problem of Capital Formation,” May 31, 1985, Center for the Study of Democratic Institutions, Santa Barbara, CA, 12–3, box 678, Center for the Study of Democratic Institutions Collection, University of California, Santa Barbara; “Stewart Tapes,” 115. At the Center for the Study of Democratic Institutions conference in 1985, Stewart spoke as an expert on small business, but he first reflected on his career, especially his work with the Center’s founder, who had died in 1977: Robert Maynard Hutchins.

25 FBI files on Milton Stewart; Senator Nelson (WI), “Small Business Administration,” Congressional Record (July 18, 1978), S21258; Civil Service Commission files on Milton D. Stewart obtained by author via Freedom of Information Act request.

26 “Stewart Tapes,” 94, 97.

27 Ibid., 97.

28 Ibid., 101.

29 Leigh to Merriam, 24 August 1944, 1; “Small Business and the Problem of Capital Formation,” 13; Milton D. Stewart, “Twentieth Century Pressure Group Techniques in the United States,” Commission on Freedom of the Press, July 1944, Communications Collection, Columbia University Libraries, New York.

30 Commission on Freedom of the Press, Free and Responsible Press, 139; FBI files on Milton Stewart; correspondence from Robert D. Leigh to Robert M. Hutchins, 8 February 1946, 2, box 9, Robert M. Hutchins Papers, University of Chicago; correspondence from Milton D. Stewart to Commission members, 6 July 1946, cover letter to Doc. 107, “Report to the Commission by Milton D. Stewart,” box 6, Commission on Freedom of the Press Papers, Columbia University; correspondence from University of Chicago Press to Chicago Tribune Library, 6 August 1948, box 27, Frank Hughes Papers, Col. Robert R. McCormick Research Center, Wheaton, IL. Stewart left his Commission job around the end of 1945, but he maintained that he was continuing to work on the book. The University of Chicago Press announced the book’s cancellation in August 1948.

31 FBI files on Milton Stewart; “Stewart Tapes,” 99–100; Senator Nelson (WI), “Small Business Administration,” Congressional Record (July 18, 1978), S21258; US Senate, The Small Newspaper: Democracy’s Grass Roots: Report of the Chairman to the Members of the Committee of the Special Committee To Study Problems of American Small Business, 79th Cong., 2d Sess., Washington, DC: Government Printing Office, January 2, 1947, print.

32 David Randall Davies, The Postwar Decline of American Newspapers, 1945-1965 (Westport, CT: Praeger, 2006), 25; Pickard, America’s Battle, 141–3.

33 FBI files on Milton Stewart.

34 President’s Committee on Civil Rights, To Secure These Rights (Washington: Government Printing Office, 1947), 48–9.

35 President’s Committee, To Secure These Rights, 49; Samantha Barbas, The Rise and Fall of Morris Ernst, Free Speech Renegade (Chicago: University of Chicago Press, 2021), 307. Ernst, who shared a draft of part of the report with J. Edgar Hoover, persuaded his fellow Committee members to tone down their criticism of the FBI.

36 “Stewart Tapes,” 101–2.

37 James T. Patterson, Grand Expectations: The United States, 1945-1974 (New York: Oxford University Press, 1996), 149–50.

38 Westbrook Pegler, “Fair Enough,” Clovis (New Mexico) News-Journal, September 14, 1951, 10. Although in that column, Pegler promised readers “a little biography of Stewart one day soon,” no follow-up article has been located in digitized newspapers or in Pegler’s papers at Syracuse University.

39 FBI files on Milton Stewart; Robert Mann, The Walls of Jericho: Lyndon Johnson, Hubert Humphrey, Richard Russell, and the Struggle for Civil Rights (New York: Harcourt Brace, 1996), 19; Senator Nelson (WI), “Small Business Administration,” Congressional Record (July 18, 1978), S21258; Steven M. Gillon, Politics and Vision: The ADA and American Liberalism, 1947-1985 (New York: Oxford University Press, 1987), 9–10, 16–20.

40 FBI files on Milton Stewart.

41 Ibid.

42 Milton D. Stewart, “The Making of Public Opinion,” Common Sense, March 1945, 33.

43 Arthur M. Schlesinger Jr., The Politics of Upheaval (Boston: Houghton Mifflin, 1960), 148.

44 George P. Rawick, “Common Sense: New York, 1932-1946,” in The American Radical Press, vol. II, ed. Joseph R. Conlin (Westport, CT: Greenwood, 1974), 450–2; Alfred M. Bingham, “Alfred M. Bingham Writes of Common Sense,” in American Radical Press, 452–6.

45 John Dewey, “Our Un-Free Press,” Common Sense, November 1935, 6–7; Schlesinger, Politics of Upheaval, 148; Rawick, “Common Sense,” 450–2; Bingham, “Alfred M. Bingham Writes,” 452–6; Common Sense masthead, November 1942.

46 Jack Gould, “The News of Radio,” New York Times, September 8, 1947, 42; New School Bulletin 5, no. 15 (December 8, 1947): 1.

47 White, American Radio, 242.

48 Ibid., 243.

49 Milton Stewart, “Radio Commentators and Free Speech,” Common Sense, August 1945, 32; Bill Bailey, “CIO May Foster Law for Free Time,” Broadcasting, August 28, 1944, 165.

50 Siepmann, Radio’s Second Chance, 107–8.

51 Ibid., 109–10.

52 Ernest Goodman, “The Air Belongs to the People,” Federal Communications Commission Bar Journal 8, (1945): 7; Morris L. Ernst, The First Freedom (New York: Macmillan, 1946), 144–5.

53 White, American Radio, 249.

54 Goodman, “Air Belongs to the People,” 8; Siepmann, Radio’s Second Chance, 113.

55 Stewart, “Radio Commentators,” 32; Siepmann, Radio’s Second Chance, 111.

56 Fones-Wolf, Waves of Opposition, 120.

57 Ibid., 120–2.

58 Ibid., 121–3; Toro, “Standing Up,” 104–13.

59 Fones-Wolf, Waves of Opposition, 123.

60 Toro, “Standing Up,” 107.

61 Fones-Wolf, Waves of Opposition, 122.

62 Goodman, “Air Belongs to the People,” 9.

63 Toro, “Standing Up,” 112.

64 Fones-Wolf, Waves of Opposition, 122.

65 Stewart, “Radio Commentators,” 33; Fones-Wolf, Waves of Opposition, 123.

66 Stewart, “Radio Commentators,” 33. A WHKC lawyer brought in other scripts for Stewart to analyze; they proved to be neutral.

67 “WHKC Battle Fails.”

68 Ibid.

69 Bill Bailey, “CIO May Foster Law for Free Time,” Broadcasting, August 28, 1944, 165.

70 In re United Broadcasting Co. (WHKC), docket 6631, FCC, June 26, 1945, 518.

71 Fones-Wolf, Waves of Opposition, 144, 124.

72 In re United Broadcasting (WHKC), 518; Fones-Wolf, Waves of Opposition, 124.

73 Simmons, Fairness Doctrine, 38–9.

74 Pickard, “Air Belongs to the People,” 313.

75 Toro, “Standing Up,” 113.

76 Ibid. Stewart later recommended creating a government office to analyze the fairness of random samples of broadcast programming. Note, “The Mayflower Doctrine Scuttled,” Yale Law Journal 59 (1950): 769–70 & n.42.

77 Kenneth Culp Davis, “Administrative Powers of Supervising, Prosecuting, Advising, Declaring, and Informally Adjudicating,” Harvard Law Review 63 (1949): 196–7.

78 Herzog, “Radio,” 303.

79 Stewart, “Radio Commentators,” 32, 33.

80 Pickard, America’s Battle, 2–3.

81 Stewart, “Radio Commentators,” 32.

82 Milton Stewart, “Tempest in Television,” Common Sense, December 1945, 32.

83 See generally Charlene Simmons, “A Marriage of Friends or Foes? Radio, Newspapers, and the Facsimile in the 1930s,” Journal of Broadcasting and Electronic Media 60 (2016): 410–24.

84 Milton Stewart, “Freedom and Facsimile,” Common Sense, January 1946, 31.

85 Ibid., 31–2.

86 Ibid., 32; “Summary of Discussion and Action: Meetings, January 27–29, 1946,” 16 March 1946, Doc. 90, 31, box 3, Commission on Freedom of the Press Records, Columbia University, New York.

87 Stewart, “FM,” 31.

88 Pickard, “Battle Over the FCC Blue Book,” 175.

89 Stewart, “FM,” 31-32; Stewart, “Tempest in TV,” 32.

90 Stewart, “Making of Public Opinion.”

91 Milton D. Stewart, “Polls Show World Unity Trend and Need for More Information,” St. Louis Post-Dispatch, July 20, 1944, 16.

92 Commission on Freedom of the Press, Free and Responsible Press, 139; “Report to the Commission by Milton D. Stewart,” Doc. 107, 1, box 6, Commission on Freedom of the Press Papers, Columbia University.

93 Stewart, “Radio Commentators,” 34.

94 Stewart, “Making of Public Opinion”; Stewart, “Tempest in Television,” 32; Milton D. Stewart, “Memorandum to Members of the President’s Committee on Civil Rights on Group Defamation and Civil Rights” (unpublished), June 1947, 17–29, https://www.bjpa.org/content/upload/bjpa/memo/MEMORANDUM%20GROUP%20DEFAMATION%20AND%20CIVIL%20RIGHTS%20AMERICAN%20JEWISH%20COMMITTEE%201947.pdf; “Radio Freedom Gets Pro and Con at ACLU Panel Discussion,” Billboard, December 1, 1945, 8.

95 “18 Radio Stations Hit Ban on Opinion,” New York Times, March 4, 1948, 20; “18 Stations Joint Fight to Editorialize Over Air,” Washington Post, March 4, 1948, 16; “Monday Through Thursday Testimony,” 78.

96 “Monday Through Thursday Testimony,” 78.

97 Correspondence from Milton D. Stewart to Selden Rodman, 3 November 1942, Alfred Mitchell Bingham Collection, Yale University, box 26.

98 Doc. 99, “Commission Meeting, Del Prado Hotel, May 6–8, 1946,” May 24, 1946, 120–1, box 6, Commission on Freedom of the Press Records, University of Washington. Robert Leigh told Commission members of Ernst’s offer.

99 “Magazine Opposes Renewal for WOL,” Broadcasting, November 5, 1945, 81; Milton Stewart, “A Fulton Lewis Jr. Bluff,” Common Sense, July 1945, 33–4; “Common Sense Agin [sic] WOL License Okay,” Billboard, November 10, 1945, 13; “Three-Way Fight Goes On; WOL, Fulton Lewis vs. Common Sense Mag,” Variety, December 26, 1945. The network did not comply, and Common Sense petitioned the FCC to withdraw Washington station WOL’s license, evidently unsuccessfully.

100 “ACLU Backs World Freedom of Air,” Broadcasting, December 3, 1945, 17.

101 Stewart, “Memorandum to Members,” 17–29.

102 Ibid., 3; Barbas, Rise and Fall of Morris Ernst, 306–8; Jerold Simmons, “Morris Ernst and Disclosure: One Liberal’s Quest for a Solution to the Problem of Domestic Communism, 1939-1949,” Mid-America 71 (1989): 15–30; President’s Committee, To Secure These Rights, 164. Ernst had long favored a ban on some forms of anonymous speech, and the Civil Rights Committee adopted his view.

103 “Radio Freedom Gets Pro and Con.”

104 Commission on Freedom of the Press, Free and Responsible Press, 89.

105 Milton Stewart, “Setting an Official Line,” Common Sense, April 1945, 29.

106 Stewart, “Memorandum to Members,” 22–8.

107 “18 Stations Join Fight to Editorialize Over Air”; Note, “Mayflower Doctrine Scuttled,” 769–70 & n.42

108 Milton Stewart, “The Age of the Atom,” Common Sense, September 1945, 30-31.

109 Storrs, “Revisiting Truman’s Federal Employee Loyalty Program,” 69; Storrs, Second Red Scare, 111. In 1951, Executive Order 10241, established new grounds for dismissing employees and required new investigations of many already-cleared workers.

110 Storrs, “Revisiting Truman’s Federal Employee Loyalty Program,” 70.

111 Robbins, “Library of Congress and Federal Loyalty Programs,” 366.

112 Weiner, Enemies, 149.

113 Storrs, “Revisiting Truman’s Federal Employee Loyalty Program,” 70; Storrs, Second Red Scare, 291–2.

114 The bureau also released about 380 pages on his then-wife, much of which duplicates material in his files. FBI files on Dorothy Overlock Stewart, obtained by author via Freedom of Information Act request.

115 Athan G. Theoharis, “Secrecy and Power: Unanticipated Problems in Researching FBI Files,” Political Science Quarterly 119 (2004): 283; FBI files on Dorothy Stewart.

116 Storrs, Second Red Scare, 263, 265; Landon R. Y. Storrs, email to author, July 2019. In response to a FOIA request, the National Archives turned over seventeen pages of Civil Service Commission documents on Stewart from 1942 and 1943 but nothing from the later screening. The Office of Personnel Management turned over one page from 1952 and another from 1954 related to Stewart’s 1950s loyalty investigations, but with no details of the FBI’s findings.

117 FBI files on Milton Stewart.

118 Ibid.

119 Ibid.

120 Ibid.; FBI files on Dorothy Stewart.

121 FBI files on Milton Stewart.

122 FBI files on Milton Stewart; FBI files on Dorothy Stewart. Although Minnix’s account prompted the expanded investigation, the FBI also took an interest in Stewart’s then-wife, who had reportedly associated with communists and fellow travelers in the late 1930s and early 1940s. Ultimately, the bureau omitted the material about her from the report on Milton Stewart “because that information is vague and the original source cannot be recontacted.”

123 FBI files on Milton Stewart; FBI files on Harold D. Lasswell, obtained by author via Freedom of Information Act request.

124 FBI files on Milton Stewart.

125 Richard Bernstein, “Sidney Hook, Political Philosopher, Is Dead at 86,” New York Times, D15.

126 On Nichols, see Susan Rosenfeld, “Biographies,” in The FBI: A Comprehensive Reference Guide, ed. Athan G. Theoharis (Phoenix: Oryx Press, 1999), 346.

127 FBI files on Milton Stewart.

128 Ibid.

129 FBI files on Llewellyn White, obtained by author via Freedom of Information Act request.

130 Ibid.

131 FBI files on Milton Stewart; correspondence from Robert Leigh to Robert M. Hutchins, 8 February 1946, 2, box 9, Robert Maynard Hutchins Papers, University of Chicago.

132 FBI files on Milton Stewart.

133 Correspondence from Llewellyn White to Max Ascoli, 24 January 1950, 2 n., box 87, Max Ascoli Collection, Boston University; FBI files on Llewellyn White.

134 FBI files on Milton Stewart.

135 Civil Service Commission files on Milton Stewart.

136 FBI files on Milton Stewart.

137 FBI files on Milton Stewart; Civil Service Commission files on Milton Stewart.

138 Myron S. Waldman, “Profile: Milton D. Stewart,” Newsday, February 18, 1965, 49.

139 FBI files on Milton Stewart; Roger Kimball, “The Power of James Burnham,” New Criterion, September 2002, https://newcriterion.com/issues/2002/9/the-power-of-james-burnham.

140 FBI files on Milton Stewart.

141 Ibid.

142 Ibid.

143 Senator Nelson (WI), “Small Business Administration,” Congressional Record (July 18, 1978), S21258; FBI files on Milton Stewart; “Milton Stewart Dies; Small-Business Expert,” Washington Post, November 7, 2004, C8. The Senate confirmed him to the SBA position despite his having signed a consent decree in 1974 agreeing to a 60-day suspension from his venture capital firm for violating Securities and Exchange Commission rules. “Milton Stewart Dies.”

144 FBI files on Milton Stewart.

145 “Milton Stewart Dies.”

146 Brinson, Red Scare, Politics, and the Federal Communications Commission, 103–4.

147 Lent, ed., Different Road Taken, 31–2.

148 Virginia Foster Durr, Outside the Magic Circle (New York: Touchstone, 1985), 217–8; Pickard, America’s Battle for Media Democracy, 118–9.

149 Storrs, “Revisiting Truman’s Federal Employee Loyalty Program,” 78 n.17; Storrs, Second Red Scare, 205, 262.

150 Pickard, “‘Air Belongs to the People,’” 322.

151 Storrs, Second Red Scare, 13.

152 Storrs, “Revisiting Truman’s Federal Employee Loyalty Program,” 70.

153 Correspondence from Langston Hughes to Patrick Malin, 8 November 1950, box 872, American Civil Liberties Union Records, Princeton University.

Additional information

Notes on contributors

Stephen Bates

Stephen Bates is a professor at the Hank Greenspun School of Journalism and Media Studies at the University of Nevada, Las Vegas. He is the author, most recently, of An Aristocracy of Critics: Luce, Hutchins, Niebuhr, and the Committee That Redefined Freedom of the Press, published by Yale University Press in 2020. He holds an A.B. and a J.D. from Harvard University.

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